PRACTICAL ANALYSIS OF TRANSFER PRICING FOR DEVELOPING 2019

Understand the importance of managing Value-Added-Tax (VAT) transactions and balances. VAT management is not rocket science, but headaches can be avoided with a proper registration and control processTo analyze the main cases of Transfer Pricing and Develop case studies related to the discussions generated at the workshop, keeping the confidentiality of tax information; in order to be of use for analysis!!!

 

Intensive Workshop on March 21th  - 22th,  2019
 

The significant increase in the volume of cross-border transactions, the growth in national budget deficits, and the inaccurate media use of transfer pricing as a tax avoidance practice or violation, are creating challenges for multinational enterprises for which cross-border transactions are simply an everyday business necessity. As such, the determination of appropriate transfer prices is relevant for all inter-company transactions, including tangibles, intangibles, services, financing, or cost allocation/sharing arrangements. In tax administrations, Transfer Pricing allow the possibility of reviewing and objecting the value of the goods and services as defined in the transactions with related parties. Because of the importance of Transfer Pricing in the tax administrations of tax administrations has developed the Transfer Pricing course, consisting of three modules: Theoretical, Practical and Advanced aspects. This workshop was held in order to keep the course updated with the latest Transfer Pricing practices. Practical Analysis of Transfer Pricing for Developing is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular. Such guidance not only assists policy makers and administrators in dealing with complex transfer pricing issues that are often manipulated to avoid paying tax, but will also assist taxpayers in their dealings with tax administrations without an effective response to transfer pricing issues, profits earned in one jurisdiction might appear to be shifted to another jurisdiction.

 

Over the course of the two days you'll learn about Pre- BEPS & Post Landscape on Corporate Tax Considerations. We'll address how government officials plan to implement the new law, how companies are adjusting their transfer pricing strategies, and how the reduced corporate tax rate could impact other countries and WTO rules. Lastly, the course intends not only to explain the theory of transfer pricing, but extend to how transfer pricing should be implemented within your business!!!

 

Learning Objectives:

  • The main objective of this course is to help participants to obtain in-depth understanding of the key aspects.

  • Considerations of transfer pricing with a focus on service fee transactions.

  • Identify the recent development in the world of transfer pricing and the impact to your business.

  • Describe the key concepts of transfer pricing such as the importance and necessity of factual, functional, industry, and economic analysis.

  • Identify potential areas of transfer pricing risks within your group and the potential countermeasures which needs to be addressed.

  • Integrate how to ensure that the arm's length pricing is correctly implemented within your business.

  • Legal Actions from Tax Authority Worldwide.

  • Counteracting Measures on Transfer Pricing in 2019 through International views.

  • Newly enacted Transfer Pricing law B.E.2561 with effective in B.E.2562.

  • Thai Revenue Department’s Benchmarks on Market Pricing and Transfer Pricing.

  • Tax rulings, Mandatory and Discourse rules.

  • Comprehensive Case study on separating contracts, supply chain management.

 

WHO SHOULD ATTEND?

The target audience is commercial and industrial companies and individual in the financial services industries engaged in the provision or receipt of intra-group services would also find the training beneficial:

  •  

  • CFOs and Finance Managers of multinationals with operations

  • Executives responsible for the tax line in the profit and loss account

  • Accountants and Internal Auditors

 

COACH'S OVERVIEW:

 

MR. BUNDIT UJJIN

 

Education:

  • Bachelor of Laws, THAMMASAT UNIVERSITY, Thailand.

  • LLM International Economic Laws, WARWICK UNIVERSITY, UK. (Thai Government Scholarship)

  • Ph.D International Tax Law, BRUNEL UNIVERSITY, UK (Thai Government Scholarship)

 

Awards:

 

B.E. 2540 Scholarship granted by Thai Government to Pursuit Postgraduate Degrees in the United Kingdom: LLM in International Economic Laws (Warwick) and PhD in International Taxation (Brunel)

 

B.E. 2551 Scholarship granted by the Government of Taiwan to be trained in “Public Finance and Decentralization of Tax Policy” at Taipei, Republic of China.

 

B.E. 2553 Scholarship granted by the Government of Japan (JICA) to be trained in “International Tax Treaty” at Tokyo, Japan.

 

B.E. 2555 Scholarship granted by Thai Government to be trained in “Business Marketing Strategy” at Kellogg School of Management, Illinois Chicago, California.

 

Work Experiences:

  • Teaching assistant in International Tax Law, Brunel University, UK.

  • Legal official: Bureau of Legal Affairs, Bureau of Investigation and Litigation, Bureau of Tax .

  • Appeal and Bureau of Large Tax Office (Banking and Financial Institution).

  • Delegation to 2008 OECD Conference on “Tax Treaties on Special Tax Issues”, Seoul, Republic of Korea.

  • Revenue Department’s working committee on “The Study Group on Asian Tax Administration and Research” (SGATAR) 2007 at Cebu Island, the Philippines.

  • Researcher in Amending and Developing Thai Revenue Code in cooperation with sponsored the Faculty of Laws, Chulalongkorn University.

  • Working Committee on the Negotiation and Amendment to Thailand and Indian Double taxation treaty.

  • Working Committee on the Advance Pricing Agreement (APA) under OECD Transfer Pricing Rules.

  • Working Committee on Granting Tax Privilege for Exporters having Compliance Records.

  • Representative to the Roundtable Conference on the Islamic Bond Market in Thailand.

  • Working Committee on “Fiscal Stimulus Measure for Insurance Business” in Thailand.

 

Academic Experiences:
+ Lecturer in Revenue Law at Faculty of Law, THAMMASAT UNIVERSITYLecturer in
   Revenue Law and International Tax Law at the Faculty of Law, RAMKAMHANG UNIVERSITY

+ Lecturer in International Tax Law at the Faculty of Accounting, UNIVERSITY OF THAI
   CHAMBER OF COMMERCE

+ Lecturer in Revenue Law at the Faculty of Accounting, UNIVERSITY OF SRIPRATUM

+ Lecturer and guest speaker invited by a number of academic institution, public
   organizations and private sectors

 

More information, please contact +662 117 3383, +662 050 8151 or email, please  Click.

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